The purpose of the Integrity Program is to support SCCA in fulfilling its commitment to meet the highest standards of legal and ethical business conduct. This is accomplished by providing guidance, information and resources to assure our workforce is aware of, and understands, their responsibilities with respect to sustaining such an environment.
- Traci Pranzini, Corporate Integrity Officer and Privacy Officer
- Dave Ackerson, Vice President, Chief Information Officer (CIO) and Chief Information Security Officer (CISO)
The Integrity Program's key functional areas include Revenue Cycle Integrity, Information Security, Privacy/Patient Confidentiality, Research Compliance, Conflict of Interest, and Stark/Anti-Kickback. The following seven elements are widely recognized and fundamental to any effective compliance program:
- Written policies, procedures and standards of conduct
- Education and training
- Lines of communication
- Auditing and monitoring
- Responding to reported issues and instituting corrective action
- Coordinate disciplinary action
Basics of the False Claims Act
Improper billing activities account for a hospital's largest compliance risks. False claims laws are targeted at health care providers who submit false claims to the government or to a third party contractor acting on behalf of the government.
- The Federal False Claims Act extends liability to any person who knowingly presents false or fraudulent claims to a government for payment. Penalties imposed can range from $5,500 to $11,000 per claim. The Act includes "qui tam" provisions that allow private citizens (relators) to sue violators on behalf of the government in return for a percentage of the recovery.
- Washington State has a similar Medicaid False Claims Act. This statute Establishes liability to the State for people or entities that submit false or fraudulent claims to Medicaid.
- The term "knowingly" means that a person: (1)has actual knowledge of the information; (2) acts in deliberate ignorance of the truth or falsity of the information; (3) or acts in reckless disregard of the truth or falsity of the information. No proof of specific intent to defraud is required.
- Examples of false claims include billing for services not rendered or products not delivered, and billing for medically unnecessary services.
SCCA privacy policies are designed to ensure that access to patient information is provided only to those who have a right to this information. You should access patient health information only when you need this information to perform your job.
- Protected Health Information (PHI) is any health information that can be used to identify a patient and that relates to the patient, healthcare services provided to the patient or the payment for these services.
- Steps you can take to protect PHI
- Limit conversations involving patients to appropriate areas.
- Keep paper containing PHI out of view of patients, visitors, and Workforce members not involved in the patient's care
- Do not leave patient information unattended in exam rooms or work areas
- Dispose of documents containing PHI in approved recycling containers
- Avoid leaving a patient's chart open on your computer screen when you leave your desk or the patient examination room.
- Log off or lock when leaving a personal computer or shared workstation.
- Never share your userID and password
Healthcare compliance means making sure we follow the applicable laws, regulations and rules in our everyday work activities. We are all committed to this goal, but it is not always easy to achieve. Healthcare laws, regulations and rules are complex. The Integrity Program needs everyone's commitment to avoid situations that are improper or even give the appearance of being improper. To this end, all workforce are required to promptly report any concerns.
- What to report? The types of issues that should be reported include: Breach of patient confidentiality; Unethical relationships with vendors or contractors; Fraudulent or false actions; Improper billing practices; Unethical behavior ; Unethical/inappropriate care of patients; Bribes or kickbacks.
- How to report?
- Anonymous Reporting. An anonymous report can be submitted by calling the Integrity hotline or by submitting a report online. SCCA non-retaliation policy for Integrity reporting protects good faith reporting.
Integrity Program Quiz Question